From New OCC & FSB AI Guidance to Exam-Ready Governance

In October 2026 the Financial Stability Board (FSB) finalized 12 Sound Practices for Responsible Adoption of Artificial Intelligence. In November 2026 the Office of the Comptroller of the Currency (OCC) published a supervisory framework for examiners evaluating banks’ use of AI, which it now calls “Super Intelligence” (SI). One is a global toolkit addressed to boards; the other is a U.S. examiner’s lens. Neither is a binding rule. Together, they describe the same destination.

Both documents say AI governance should be built into existing risk frameworks rather than bolted on, and that control intensity should scale with the consequences of failure. Both expect a complete inventory of AI use, consistent risk tiering, human oversight that is meaningful rather than nominal, continuous monitoring, tamper-resistant records, and rigorous oversight of third-party AI. Both single out agentic AI as the frontier where risk grows fastest.

The practical message for financial institutions is simple: the evidence an examiner will ask for has to exist before the exam, in one place, and tie out. Institutions still running AI governance on spreadsheets, email approvals and periodic reviews will struggle to show that. CapTech created SentryPoint AI to close exactly that gap.

Regulators have spent several years signaling interest in AI. These two publications are different: they are specific. The OCC framework gives examiners 16 components and an illustrative four-tier risk model to tailor their supervisory work. The FSB report gives boards 12 practices, a seven-stage AI lifecycle, and case studies showing how institutions have applied them proportionately.

For U.S. national banks, the OCC framework is effectively a preview of exam conversations. For insurers, asset managers, payments firms and internationally active groups, the FSB report is the clearest global reference point, and one that national authorities and sector standard-setters typically build on. Both bodies describe their documents as living and expect to update them as technology evolves.